Privacy and Cookie Policy

Last updated on May 25, 2018

SmartBrief, Inc. ("SmartBrief","we" or "us") is a media company offering industry-focused newsletter and content services in partnership with trade associations, professional societies, nonprofits and corporations (in this document we collectively refer to these organizations, our advertisers, social media partners, service providers and certain other parties as our "Business Partners").

This privacy and cookie policy (“Policy”) describes how we collect, use and share personal data through our “Services,” including in connection with our email newsletters (the “Newsletters”), and when using this website (the “Website”) and/or our mobile apps (the “App”).

Information Collection and Use

We collect information about you in a range of forms, including personal data. Personal data includes any information that, either alone or in combination with other information held about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number. We collect and use your personal data to:

provide relevant, personalized, targeted news and information;

help target advertising messages, including in our email newsletters and other communications, so that we are able to continue providing our content to you at no cost;

operate, maintain, and improve our Services;

enable our customer service professionals to respond to your questions, concerns and feedback;

manage your subscriptions to our Services, including communicating with you about your subscriptions; and

send information, including technical notices, updates, security alerts, and support and administrative messages.

Data We Collect

Information You Provide Us. SmartBrief collects personal data, such as name, email address, postal address, ZIP code and country, from each subscriber to our Services. Personal data can be used to identify or contact you directly. We also collect the name of your company, job title, level in organization, job function, company type, company revenue and number of company employees. We typically collect this information directly when you complete registration forms or when you provide other information through our Website or via email. When we collect this information directly, we let you know if providing the information is optional or if it is required to provide our Services (for example, we must have your email address to provide you with our email newsletter Services).

Information Provided to Us by Our Business Partners. We also collect personal data indirectly when we receive it from our Business Partners. We may combine information we have collected directly from you with information we obtain from Business Partners or other companies.

When we obtain personal data from our Business Partners, that information will be subject to the privacy policy of the Business Partner, which is different from SmartBrief ’s policy. However, SmartBrief generally asks that Business Partners have a relationship with you prior to sending us your information. For example, for Business Partners that are trade associations, we generally ask that they send us information only from persons who are affiliated with their trade association, or persons whom they reasonably believe have an interest in that trade association, and that they are complying with applicable laws with respect to the information they send. From time to time, SmartBrief hosts co-branded registration for some services provided by or in conjunction with our Business Partners. In those cases, we generally ask that our Business Partners adhere to the privacy principles listed here.

Nevertheless, we are not responsible for the privacy policies of our Business Partners and strongly encourage you to visit the privacy policy of any website prior to providing your information. Sometimes, we provide links to our privacy policy and that of our Business Partner on the same webpage when information you enter may be subject to both.

Information from Social Networking Sites. Our Services include an interface that allows you to connect with social networking sites, for example, Facebook, LinkedIn, Twitter, or Google+ (each an "SNS"). If you connect to an SNS through our Services, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS. We also may enable you to post content to SNSs. You acknowledge and agree that you are solely responsible for your use of the SNSs and that it is your responsibility to review the terms of use and privacy policy of the third-party provider of such SNSs. We will not be responsible or liable for the availability or accuracy of such SNSs, the content, products or Services on or availability of such SNSs, or your use of any such SNSs.

Information Automatically Collected. We automatically log information about you and your computer or mobile device when you use our Services, including visiting our Website, using one of our Apps, and reading our email newsletters.

For example, when using our Services, we log when you open an email from us, what links in our emails that you select, your IP address, your computer or mobile device operating system name and version, manufacturer and model, browser and email client type, internet browsing and usage habits, your internet service provider, browser language, pages you viewed, how long you spent on a page, access times, the website that referred you to our Services, and information about your use of and actions on our Website. We collect this information about you using cookies (see ’Cookies’ section) and pixel tags (see ’Pixel Tags’ section).

This data generally are used to help us administer our Services, to improve our product offerings and in other ways set forth in this privacy policy.

Cookies

Cookies are small data files stored on the hard drive of your computer or mobile device by a website. Session cookies are generally used to aid navigation on our Website, while persistent cookies allow us to maintain information between visits, such as the number of site visits, and user preferences, such as your username. A persistent cookie remains on your hard drive for a limited time period, after which it expires and is deleted by your browser. For more information about cookies, please visit http://www.allaboutcookies.org/cookies/.

Cookies We Use

We use the following types of cookies for the purposes set out below:

Essential Cookies. These cookies are essential to provide you with our Services and to enable you to use some of the features of our Services. Without these cookies, the Services cannot be provided, and we only use these cookies to provide you with the Services.

Functionality Cookies. These cookies allow our Website to remember choices you make when you use our Website. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Website.

Analytics and Performance Cookies. These cookies are used to collect information about traffic to our Website and how users use our Website. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. In addition, our measurement partners (including Google Analytics) use cookies on our Services to help advertisers understand the effectiveness of their advertising campaigns and to compare the performance of those campaigns to ads displayed on other websites and apps.

Advertising & Targeting Cookies. These cookies track your browsing habits to enable us to show advertising that is more likely to be of interest to you, both on and off our Services and to measure the effectiveness and reach of ads and services. These cookies use information about the industries you are interested in and your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third-party advertisers can place cookies to enable them to show advertisements that we think will be relevant to your interests while you are on third-party websites.

Social Media Cookies. These cookies are used when you share information using a social media sharing button or “like” button on our Website or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, LinkedIn or Google+. The social network will record that you have done this.

Disabling Cookies

You can typically remove or reject cookies via your browser settings. To do this, follow the instructions provided by your browser (usually located within the "settings", "help", "tools" or "edit" menus). Many browsers are set to accept cookies until you change your settings.

If you reject the cookies, you still may use our Services. However, please note that if you disable cookies, the functionality offered by the Services may be limited as a result.

Pixel Tags

We may use pixel tags (also known as web beacons and clear GIFs) on our Services to track the actions of users on our Services. A pixel tag is a tiny, opaque graphic image, usually no larger than 1 pixel x 1 pixel, which is placed on a website or in an email that is used to monitor the behavior of the user. Pixel tags measure how relevant our newsletter content is to our subscribers, measure the success of our marketing campaigns, and compile statistics about usage of the Services, so that we can manage our content more effectively and provide our readers with more useful content.

Information Sharing and Disclosure

We may share your personal data and other types of data as follows:

Business Partners. Periodically, we may share information, including personal data, collected from you with trade associations and other Business Partners with whom we do business. For example, if you subscribe to a SmartBrief newsletter service sponsored by a trade association, we may provide your information to that trade association, including your name, email address, postal address, company and title. That trade association may contact you or invite you to participate in other association activities. We also share de-identified information and/or aggregated information with our Business Partners.

Advertisers. We do not share personal data with advertisers, except in accordance with this policy and where you have given us permission to do so. For example, you may give us permission to share your personal data with a third party in connection with an advertiser’s lead generation campaign. We may also pre-fill a lead generation form with your personal data for you to submit directly to one of our advertisers. We also share de-identified information and/or aggregated information with our advertisers.

Social Networking Sites. We share de-identified information with our social media partners, to enable them to show advertising that is more likely to be of interest to you.

Third Parties. If you supply information directly to SmartBrief, a Business Partner or an advertiser via a registration form in the Service (including our Website and Apps) as part of a promotion, advertiser lead-generation campaign, contest, third-party subscription or similar activity, we may supply both personal data and anonymous data you provide directly to our Business Partner and/or advertiser. In addition, when you provide such information, we may retain this information and use it to augment your subscriber profile for our records and possible later use as provided in this Policy. If SmartBrief, a Business Partner or an advertiser is conducting a promotion or campaign on our Website or App in which your information will be collected by SmartBrief and shared in ways other than as set forth in this Policy, we will disclose such sharing prior to the transfer and you will be given the opportunity to request that your information not be shared. In some cases, you may not be able to participate in a particular promotion or campaign if you have chosen not to share personal data. SMARTBRIEF MAY PROVIDE YOUR PERSONALLY IDENTIFIABLE INFORMATION TO A THIRD-PARTY COMPANY WITH YOUR CONSENT. BECAUSE WE DO NOT CONTROL THE PRIVACY PRACTICES OF THESE THIRD-PARTY COMPANIES, YOU SHOULD READ AND UNDERSTAND THEIR PRIVACY POLICIES.

Aggregated Data

We also aggregate information about our subscribers and the ways they use our Services. This information does not identify you personally. We use this information for market research purposes and to improve the quality of the Services we offer. We reserve the right to disclose aggregated, anonymous data we have collected to third parties for any purpose.

NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

(AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83)

A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES (A “CALIFORNIA CUSTOMER”) MAY REQUEST INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL INFORMATION TO ANY THIRD PARTIES FOR THE THIRD PARTIES’ DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED. CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH THIS LAW BY EMAILING privacy@smartbrief.com. PLEASE NOTE THAT WE ARE REQUIRED TO RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR AND WE ARE NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS EMAIL ADDRESS.

Third-Party Service Providers. Except in accordance with this policy, SmartBrief does not rent, sell or share your personal data with nonaffiliated third parties without your consent. SmartBrief may, however, share personal data with trusted third-party service providers and contractors. These third-party service providers and contractors are prohibited from using the information for purposes other than performing services for SmartBrief. A list of our service providers can be found at http://smartbrief.com/privacy/data-processors.

Corporate Restructuring. SmartBrief may transfer information, including any personal data, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If SmartBrief is involved in a merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your information, as well as any choices you may have regarding your personal data.

Other Disclosures. SmartBrief may disclose your information to third parties (a) when obligated to do so by law, or in connection with a subpoena, court orders or legal process, (b) to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person, (c) to enforce our privacy policy, and (d) to protect our rights, privacy, safety or property, and/or that of you or others. We reserve the right to disclose aggregated, anonymous data we have collected to third parties for any purpose.

Security

SmartBrief has security measures in place designed to protect the loss, misuse and alteration of the information under our control. Our hardware infrastructure is housed in a controlled access facility that restricts access to authorized individuals with positive identification. The network infrastructure is protected by a firewall and traffic is monitored and logged both on the firewall and servers. Administrative access is limited not only to authorized employees but also to specific remote administration protocols. All employees with access to personal data are trained in SmartBrief’s security policies and practices. SmartBrief will continue to conduct internal reviews of its security systems and make all necessary enhancements to ensure the safety of the Website and its users. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while SmartBrief strives to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

Children's Privacy

SmartBrief’s products and Services are designed for those ages 18 and older. SmartBrief does not intentionally gather personal data from visitors who are under the age of 13. If a child under 13 submits personal data to us and we learn that the personal data is the information of a child under 13, SmartBrief will delete the information as soon as reasonably practicable. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@smartbrief.com.

Advertising Choices and Subscription Preferences

SmartBrief collects data, including de-identified data, via our Services, and via the websites of our Business Partners and other third parties, to help tailor content and advertising. We also enable Business Partners and other third parties to collect and/or use de-identified data from our Services. Cookies and web beacons are typically used to help collect this information. We support the industry self-regulation program established for Online Behavioral Advertising (“OBA”). For more information about these practices, and to learn about the choices available to you regarding how this information is used, please visit www.AboutAds.info. The site provides you with an option to opt out of some or all OBA as you prefer. Please note that preferences are stored separately for each browser and device you use, so you may have to repeat the opt-out process if you wish your preferences to apply universally.

Each email sent through the SmartBrief system contains an easy, automated way for you to stop receiving that newsletter. To unsubscribe, select the "unsubscribe" link in the footer of an email from SmartBrief and follow the directions to communicate your preferences to us. Alternatively, you may reply to your SmartBrief email and type the word "UNSUBSCRIBE" in the subject line.

We also encourage you to participate in our referral program to share SmartBrief with a friend or colleague. When you provide us with a referral’s email address, we store this information for the sole purpose of sending the referral a one-time email inviting that person to register on the Website. We will not send newsletters or any additional emails until your referral has indicated to us that they desire to receive such material..

Your Rights

Opt out. You may contact us anytime to opt out of: (i) marketing communications; (ii) our collection of sensitive personal data; (iii) any new processing of your personal data that we may carry out beyond the original purpose; or (iv) the transfer of your personal data outside the European Economic Area (the EU, UK, Iceland, Liechtenstein and Norway). Please note that your use of some of our Website and receipt of our email newsletter services may be ineffective upon opting out.

Access. You may access the personal data we hold about you at any time by contacting us directly.

Amend. You can update or correct any inaccuracies in your personal data. To change such information, follow the link provided in the confirmation email you received upon registering, or visit https://www.smartbrief.com/subscribertools/login.jsp and log in with the credentials you provided when you first registered.

Move. Your personal data is portable – i.e. you have the flexibility to move your personal data to other service providers as you wish.

Erase and forget. In certain situations -- for example, when the information we hold about you is no longer necessary to provide the Services, is incorrect or you want to withdraw your consent to our holding of your data -- you can request that we erase your personal data.

If you wish to exercise any of these rights, please contact us at privacy@smartbrief.com. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to exercise. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and, in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

International Data Transfer

Information collected or used by SmartBrief pursuant to this privacy policy may be transferred, used and stored by us and our third-party service providers outside the country in which you reside, including but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Services, you agree to this storing, processing or transfer.

If you use our Services, you consent to the capture, storage, transfer, use and processing of your information under the laws of the United States. This does not affect your rights and freedoms under the General Data Protection Regulation 2016/679 (GDPR) and any successor legislation. You agree that all transactions relating to SmartBrief shall be deemed to have occurred in the United States, where we currently have our personnel and operations.

Data Retention

We will only retain your personal data as long as reasonably required for you to use the Services, unless a longer retention period is required or permitted by law (for example for regulatory purposes).

Sensitive Personal Data

Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (for example, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

If you send or disclose any sensitive personal data to us, you consent to our processing and use of such sensitive personal data in accordance with this privacy policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such content.

Complaints

We are committed to resolving any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this privacy policy or our practices in relation to your personal data, please contact us at privacy@smartbrief.com. We will respond to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention. However, if you feel that we have not adequately addressed your complaint, you reserve the right to contact your local data protection supervisory authority.

Changes to this Privacy Policy

This privacy policy is subject to change. If SmartBrief makes any substantive changes to the way we use personal data or other data under our control, we will post a clear and conspicuous notice that we have updated our privacy policy on our Website and/or in our newsletter Service prior to the changes being made.

Contacting Us

The data controller of your personal data is SmartBrief, Inc., 555 11th Street NW, Washington, DC 20004. For any questions you may have about our Services or this Privacy and Cookie Policy, please email us at privacy@smartbrief.com.